Tax treaty definitions clarify territorial scope, covered taxpayers, competent authority roles and the concept of international traffic. Article 3 defines territorial scope, treating specified maritime zones as part of each Contracting State for treaty purposes; defines tax for the Convention while excluding penalties; and sets out covered taxable persons, company, and enterprise of a Contracting State as industrial, mining, commercial, plantation, agricultural or similar undertakings carried on by residents. It also identifies the competent authority, the meaning of national, and international traffic, and provides that undefined terms take their meaning from the domestic law of the applying State unless the context requires otherwise.
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Tax treaty definitions clarify territorial scope, covered taxpayers, competent authority roles and the concept of international traffic.
Article 3 defines territorial scope, treating specified maritime zones as part of each Contracting State for treaty purposes; defines tax for the Convention while excluding penalties; and sets out covered taxable persons, company, and enterprise of a Contracting State as industrial, mining, commercial, plantation, agricultural or similar undertakings carried on by residents. It also identifies the competent authority, the meaning of national, and international traffic, and provides that undefined terms take their meaning from the domestic law of the applying State unless the context requires otherwise.
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